Time-Critical Removal Action:  Manufacturing/Processing/Maintenance – Electroplating, Metal Finishing

See Initial Polrep.

1.1.2.1 Location

The Baycote Metal Finishing Site is located at 1302 Industrial Drive in Mishawaka, St. Joseph County, Indiana 46544.  The geographical coordinates for the Site are 41°39’0.03” North latitude and 86°09’57.11” West longitude.  The Site is bordered by industrial properties to the north, east, and south and Industrial Drive and industrial properties to the west.  Residential properties are located approximately 700 feet to the west.  Seven churches and two schools are located within 1 mile of the Site. The St. Joseph River, a major surface water body that terminates in Lake Michigan, is located 0.85 mile northwest of the Site. 

1.1.2.2 Description of Threat

See Initial Polrep.

1.1.3 Preliminary Removal Assessment/Removal Site Inspection Results  
See Initial Polrep.

In a letter dated November 11, 2011, the St. Joseph County Health Department (SJCHD) requested assistance from the U.S. EPA to secure hazardous wastes left on-site.  SJCHD was concerned that the Site posed a significant threat to the health and safety of companies within the industrial park as well as the residential area located less than a 1,000 feet from the facility.  On February 23, 2012, the Director of U.S. EPA's Superfund Division approved an Action Memorandum for a time-critical removal action at the Baycote Metal Finishing Site.

On April 6, 2012, U.S. EPA issued a Unilateral Administrative Order to the potentially responsible parties to conduct a removal action at the Site.  The potentially responsible parties presented and inability to pay argument and indicated that they did not intend to conduct a removal action at the Site.  EPA began time-critical removal actions at the Baycote Site on May 29, 2012. 

2.1.2 Response Actions  

- EPA and START continued to conduct site perimeter and work area air monitoring to ensure worker and community protection.             

- Cleanup of the plating areas is completed.  ERRS cleaned / powerwashed the floors and collected rinsewaters for off-site disposal.

- Clean up in Area W was initiated.  Wastewater treatment chemicals located in tanks / containers were removed and the tanks / containers were cleaned and rinsed.  Rinsewaters were collected for off-site disposal.  The wastewater treatment system is located above a containment pit that contains water / sludge.  START collected 5-water samples and 5-sludge samples from the area to determine the threat to human health and the environment.

- ERRS decontaminated site equipment; rinsewaters were collected for off-site disposal.      

- Site wastes were relocated to Areas E and Z for staging for off-site disposal.  Containers were segregated according to hazard classification / compatibility.  The wastes are in the process of being profiled for acceptance to off-site disposal facilities.  Profiled wastes were labeled accordingly, and wastes with laboratory analysis pending were identified.  

- Empty containers / equipment were demolished and placed into the appropriate roll-off for off-site disposal.        
      
- ERRS placed telescoping floor jacks in Area J to add structural support during the winter months.     

- EPA and its contractors implemented Green Practices onsite (double sided printing, Culligan water service / dedicated water bottles, dedicated steel toed Chem boots, city electrical power, CFL bulbs, etc...).  To date approximately 101,460 pounds of scrap steel has been recycled.  EPA also provided a pallet of thirty eight 5-pound bags of Alka40 (Calcium Hydroxide) for reuse to the US Ecology facility.  Water service / reusable dedicated water bottles saved approximately 3,100 disposable water bottles.      

- EPA, ERRS and START demobilized from site for the winter months.  EPA and ERRS will return to the site to facilitate transportation of staged wastes for off-site disposal. 

- On November 5, 2012, EPA conducted a walkthrough with Mishawaka Fire Department, City of Mishawaka, and Indiana Department of Environmental Management personnel.  EPA outlined response activities, the current status of the site, and future plans.  

- 24-hour site security will remain until staged wastes are transported off-site. 


2.1.4 Progress Metrics

The following waste has been staged for disposal as of November 5, 2012:

28 55-gallon drums of Haz basic vat bottom sludge

22 55-gallon drums of Haz acid vat bottom sludge

8 cubic-yard boxes of Haz solids

1 330-gallon tote Haz base liquid

3 55-gallon drums Haz base liquid

31 330-gallon tote Haz neutral liquid

3 55-gallon drums of Haz neutral solids

2 330-gallon Haz oily solids

1 cubic-yard box oily solids

1 95-gallon overpack of Sodium Hydrosulfite

2 55-gallon drums of Sodium Hydrosulfite

1 95-gallon overpack of Hydrogen Peroxide

2 55-gallon drums of Hydrogen Peroxide

5 55-gallon drums of Non-Haz oil/water mix

2 55-gallon drums of Flammable Liquids

1 cubic-yard box of Calcium Hydroxide

2 -55 gallon drums of potassium permanganate

1 55-gallon drum bleach solution

1 55-gallon drum ferric sulfate

1 55-gallon drum neutral oxidizing liquid

4 330-gallon totes pending analysis (likely Haz neutral liquids)

1 330-gallon tote pending analysis (likely Haz cyanide liquids)

4 55-gallon drums pending analysis (likely Haz cyanide liquids)

2 55-gallon drums pending analysis (likely Haz cyanide solids)

4 55-gallon drums pending analysis from Tank E15

6 55-gallon drums pending analysis from Area Z

5 55-gallon drums unknown solids pending analysis

1 55-gallon drum pending analysis from decontamination water sludge

5 boxes universal waste fluorescent light bulbs

25 Miscellaneous Lab Pack

Planned removal activities on Site included:

1. Inventory and perform hazard categorization on substances contained in vats, pits, drums, and other containers; 
2. Perform sampling and analysis to determine disposal options.
3. Continue to consolidate and package hazardous substances, pollutants, and contaminants for  
   transportation and off-site disposal;  
4. Dismantle and decontaminate process equipment and building components associated with 
   the plating areas, as necessary;
5. Transport and dispose of all characterized or identified hazardous substances, pollutants, or 
   contaminants to a RCRA/CERCLA-approved disposal facility in accordance with U.S. EPA 
   Off-Site Rule (40 CFR § 300.440). 
6. Take any other response actions to address any release or threatened release of a hazardous substance, pollutant and contaminant that the U.S. EPA OSC determines may pose an imminent and substantial endangerment to the public health or the environment. 

2.2.1.2 Next Steps

During the week of November 12, 2012, the following activities are anticipated:

- Arrange for transportion of staged site wastes to licensed disposal facilities (Several trailers are scheduled for the week).     
- Continue to submit waste profiles to selected disposal facilities.

2.2.2 Issues

Area W is located under a structurally unsound area of the building (partial roof collapse).  ERRS placed temporary shoring in the Area to provide limited access and removed chemicals associated with the wastewater treatment process (sulfuric acid, bleach, ferric sulfate, etc.).  Water / sludge is located in a containment pit below the wastewater treatment system.  START collected samples to determine the threat of the remaining water / sludges.  Any future removal actions in Area W requires the removal of the collapsed roof to access the containment pit.   Additional areas of the building are also structurally unsound with any additional loading from snowfall.  Due to safety concerns to site workers, work through the winter months has been suspended.  Analytical data from the START sampling event will be used to determine future actions. 

* The above accounting of expenditures is an estimate based on figures known to the OSC at the time this report was written. The OSC does not necessarily receive specific figures on final payments made to any contractor(s). Other financial data which the OSC must rely upon may not be entirely up-to-date. The cost accounting provided in this report does not necessarily represent an exact monetary figure which the government may include in any claim for cost recovery.

The Health and Safety Plan was approved and signed by all site personnel. 

2.5.2 Liaison Officer
NA

2.5.3 Information Officer:
Community Involvement Coordinator: Ginny Narsete

IDEM

City of Mishawaka

St. Joseph County Health Department

Mishawaka Fire Department
ATSDR
Federal Occupational Health
South Bend HazMat

The following numbers of personnel were On-Site during the reporting period:

Baycote            Baycote Metal Finishing Site

CERCLA           Comprehensive Environmental Response, Compensation, and Liability Act
CRZ                  Contamination Reduction Zone

EPA                 Environmental Protection Agency
ERT                  Environmental Response Team

ERRS               Emergency and Rapid Response Services

FCA                 Field Cost Accountant

FOH                 Federal Occupational Health
HASP               Health and Safety Plan

HAZCAT            Hazardous Categorization 
IDEM                Indiana Department of Environmental Management

NA                    Not Applicable

OSC                 On-Scene Coordinator

PolRep              Pollution Report

RCRA                Resource Conservation and Recovery Act

PRP                  Potentially Responsible Party

RM                    Response Manager

POLREPS will be issued on a weekly or bi-weekly basis.